Privacy Policy

1 About This Policy

phll Casino operates phll.club as an online gaming platform serving Filipino players throughout the Philippines. As a platform handling personal and financial information of registered players, phll is committed to protecting your privacy in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its implementing rules and regulations as administered by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy explains in plain terms what personal data phll collects about you, why phll collects it, how it is used and stored, who it may be shared with, and what rights you have as a data subject under Philippine law. This Policy applies to all personal data processed by phll in connection with your use of phll.club, including during account registration, deposit and withdrawal transactions, game play, customer support interactions, and promotional communications.

2 Data We Collect

phll collects the following categories of personal data from players and users of the phll platform:

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification — phll is strictly 21+ only);
• Nationality and country of residence;
• Residential address (street, city, province, postal code);
• Government-issued identification documents (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID) submitted for KYC verification.

2.2 Contact Data

• Mobile number (Philippine +63 format for SMS communications and GCash/PayMaya link verification);
• Email address used for Account registration and communications.

2.3 Financial & Transaction Data

• GCash account number or registered mobile number;
• PayMaya account number;
• Bank account details (account name, account number, bank name) for BPI, BDO, Metrobank, and UnionBank withdrawals;
• Visa/Mastercard card details processed via our PCI-DSS compliant payment gateway;
• Cryptocurrency wallet addresses for USDT TRC20 transactions;
• Complete deposit and withdrawal transaction history on phll;
• Gaming wager history, game outcomes, and account balance movements.

2.4 Technical & Usage Data

• IP address and approximate geographic location derived from IP;
• Device type, operating system, and browser information;
• Session duration, login timestamps, and pages visited on phll.club;
• Game play logs and platform interaction data collected for security and fraud detection purposes.

2.5 Communications Data

• Records of all Customer Support interactions via live chat, email, or other phll support channels;
• Your responses to surveys, promotions, and feedback requests from phll.

3 How We Collect Data

phll collects your personal data through the following means:

• Directly from you — when you register an Account on phll, complete KYC verification, make a deposit or withdrawal, contact Customer Support, or respond to a phll promotion;
• Automatically via the phll platform — through server logs, cookies, and tracking technologies when you browse or use phll.club (see Section 8 for detailed cookie information);
• From payment processors — when you initiate a deposit or withdrawal, your payment provider (GCash, PayMaya, bank, card network) shares transaction confirmation data with phll;
• From identity verification services — phll may use third-party KYC verification providers to cross-check identity documents against authoritative databases as part of our anti-money laundering compliance obligations;
• From fraud prevention services — phll uses third-party fraud detection tools that may collect device fingerprint and behavioral data to protect the platform and its players.

4 How We Use Your Data

phll processes your personal data for the following specific purposes:

phll does not use your personal data for any purpose not listed above without first obtaining your express consent or as otherwise required by applicable Philippine law.

5 Legal Basis for Processing

phll processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations to you under the phll Terms & Conditions, including Account management, payment processing, and providing gaming services;
• Legal obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, tax obligations, and other applicable Philippine law;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring — balanced against your rights and interests as a data subject;
• Consent: Processing for promotional communications and non-essential cookies, which you may withdraw at any time without affecting your ability to use the phll platform.

6 Sharing Your Data

phll does not sell your personal data to any third party. phll may share your personal data with the following categories of recipients under strict confidentiality obligations:

• Payment processors and e-wallet providers (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, Visa, Mastercard, and others) — to process your deposit and withdrawal transactions;
• KYC and identity verification service providers — to verify your identity and age in accordance with our regulatory obligations;
• Fraud detection and cybersecurity service providers — to protect phll players and the platform from unauthorized access and fraudulent activity;
• Game software providers — limited game play data is shared with providers (such as PG Soft, Pragmatic Play, Evolution Gaming) to resolve game disputes and technical issues;
• Regulatory authorities — including PAGCOR and the National Privacy Commission, when required by applicable law or regulatory obligation;
• Law enforcement agencies — when required by valid legal process, court order, or to protect the legal rights of phll or its players.

All third-party service providers with whom phll shares personal data are contractually required to maintain the confidentiality and security of that data and to process it only for the specific purposes for which it was shared.

7 Data Retention

phll retains your personal data for as long as your Account is active and for a period thereafter as required by applicable law or legitimate business purposes. Specific retention periods applicable to phll player data are as follows:

• Account and identity data: Retained for the duration of your Account and for a minimum of 5 years following Account closure, as required for AML compliance under Philippine law;
• Transaction and financial records: Retained for a minimum of 5 years from the date of each transaction in accordance with anti-money laundering regulatory requirements;
• Game play logs: Retained for 2 years from the date of each session for dispute resolution and regulatory audit purposes;
• Customer Support communications: Retained for 3 years from the date of each interaction;
• Marketing consent records: Retained until you withdraw consent or close your phll Account, plus 1 year for audit purposes.

When personal data is no longer required for any lawful purpose, phll will securely delete or anonymize it in accordance with our data disposal procedures.

8 Cookies & Tracking Technologies

phll.club uses cookies and similar tracking technologies to operate the platform and improve your experience. The categories of cookies used on phll.club are:

• Strictly necessary cookies: Required for platform operation including session management, login state, and security functions. These cannot be disabled without affecting platform functionality;
• Performance and analytics cookies: Collect anonymized data on how players use phll.club to help us improve platform performance and navigation;
• Functionality cookies: Remember your language preferences, game history, and display settings to provide a personalized phll experience;
• Security cookies: Detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts on the phll platform.

You may manage non-essential cookie preferences through your browser settings. Blocking strictly necessary cookies will impair your ability to use the phll platform. For most Filipino players using Chrome on Android, cookie preferences can be managed through Chrome's site settings menu at phll.club.

9 Data Security

phll implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and phll.club;
• Encryption at rest for sensitive personal and financial data stored in phll's databases;
• Strict access controls ensuring that only authorized phll personnel with a need-to-know basis can access player personal data;
• Regular security audits, penetration testing, and vulnerability assessments of the phll platform;
• Two-factor authentication (2FA) available to all phll players for Account login security;
• PCI-DSS compliant payment gateway handling for card transactions — phll does not store full card numbers on its servers.

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phll will notify the National Privacy Commission within 72 hours of becoming aware of the breach and will communicate directly with affected players as required by the DPA.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its implementing regulations, you have the following rights with respect to your personal data held by phll:

• Right to be Informed: The right to know that your personal data is being collected and processed, and for what purposes — which this Privacy Policy fulfills;
• Right to Access: The right to request a copy of the personal data phll holds about you and information about how it is processed;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data in your phll Account;
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data in circumstances where it is no longer necessary for its original purpose, subject to phll's legal retention obligations;
• Right to Object: The right to object to processing of your personal data for direct marketing or based on phll's legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Damages: The right to claim compensation for damages resulting from inaccurate, incomplete, outdated, or unlawfully obtained personal data processed by phll.

To exercise any of the above rights, please contact phll's Data Protection Officer using the contact information in Section 14. phll will respond to all data subject requests within 15 business days of receipt. Identity verification will be required before processing any data access or erasure request.

11 Children's Privacy

phll Casino is strictly an adult gaming platform. All real-money gaming services on phll are exclusively available to individuals 21 years of age or older in accordance with PAGCOR regulations. phll does not knowingly collect or process personal data from individuals under the age of 21.

If phll becomes aware that personal data has been collected from an individual under 21 years of age, the associated Account will be immediately suspended, the personal data will be securely deleted, and any deposited funds will be returned via the original payment method following identity confirmation. If you believe that an underage person has created an Account on phll, please contact our Customer Support team immediately.

12 Cross-Border Data Transfers

In the course of providing its services, phll may transfer certain personal data to third-party service providers located outside the Philippines — for example, game software providers, cloud infrastructure providers, or fraud detection service providers with operations in other countries. Any such cross-border transfer of personal data by phll is conducted in accordance with the requirements of the Data Privacy Act of 2012, including ensuring that the receiving party provides an adequate level of data protection through contractual safeguards or other legally recognized mechanisms.

phll does not transfer personal data to jurisdictions that the National Privacy Commission has identified as providing inadequate data protection without first obtaining your explicit consent or implementing appropriate contractual protections.

13 Changes to This Privacy Policy

phll reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or platform operations. Material changes to this Policy will be communicated to registered phll players via email notification or prominent in-platform notice at least 7 days before the amended Policy takes effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the phll platform after the effective date of any amendment constitutes acceptance of the updated Privacy Policy. If you do not agree with any changes, you should discontinue use of phll and may contact Customer Support to close your Account.

14 Contact Us

For all privacy-related inquiries, data subject access requests, or complaints regarding phll's data processing practices, please contact phll's Data Protection Officer through the following channels:

• Support Email: support@phll.club (please include "Privacy Policy Inquiry" in your subject line)
• Live Chat: Available 24/7 through the phll.club platform — ask to speak with the Data Protection team

phll will acknowledge all privacy inquiries within 48 hours and will provide a substantive response within 15 business days. If you are not satisfied with phll's response to your privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.